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       #Post#: 61242--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: b789
       Date: March 7, 2025, 1:43 pm
       ---------------------------------------------------------
       Attaching a photo of the knee and knee brace are useless. You
       will need to get a doctors letter confirming the temporary
       disability. How long has the driver had this disability?
       #Post#: 61255--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: ixxy
       Date: March 7, 2025, 3:39 pm
       ---------------------------------------------------------
       Good advice from DWBM2 about how to word the appeal. Keep it to
       the point.
       #Post#: 61257--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: gliderpilot63
       Date: March 7, 2025, 3:48 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > Attaching a photo of the knee and knee brace are useless. You
       will need to get a doctors letter confirming the temporary
       disability. How long has the driver had this disability?
       >
       --- End Quote ---
       OK
       he has had the disability for circa 15 years, knee replaced
       circa 10 years ago.
       #Post#: 63476--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: gliderpilot63
       Date: March 20, 2025, 11:18 am
       ---------------------------------------------------------
       So, the attached letter was received today.  No acknowledgement
       of the driver's mobility issues raised in the initial latter but
       a continued request to try to get the driver's identity from the
       keeper.  Any advice on the next step anyone please?
       [attachment deleted by admin]
       #Post#: 63477--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: DWMB2
       Date: March 20, 2025, 11:23 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > In this case, yes, it is better to appeal as the driver. They
       will need to provide some evidence of their disability.
       >
       --- End Quote ---
       I thought the appeal had already named the driver, in order to
       provide evidence of the disability?
       #Post#: 63482--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: gliderpilot63
       Date: March 20, 2025, 11:33 am
       ---------------------------------------------------------
       no the appeal was by the keeper who confirmed that the driver
       was mobility impaired, asking that Parkingeye to reconsider the
       consideration period in view of that.  given the potential
       defects in the NtK the keeper wanted to first mention the
       driver's mobility impairments.  should the keeper now divulge
       the driver's identity and so rely entirely on the disability?
       one poster was going to draft a letter but did not post.  the
       driver does not want to trouble his GP at this stage for
       correspondence confirming that the knee has been replaced
       because this can be evidenced by scars confirming the fact that
       the knee has in fact been replaced.
       #Post#: 63735--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: gliderpilot63
       Date: March 22, 2025, 11:50 am
       ---------------------------------------------------------
       Any suggestions as to how to progress?
       I was originally hoping for a draft letter afterI posted the NtK
       but when one was not posted I had a go at drafting as I had
       found another thread where Parkingeye were the offending
       company.  My second draft following comment noted that the
       appeal was as keeper (not as driver) and the main comment seemed
       to relate to the evidence to be provided to support the mobility
       impairment and not the nature of who should be appealing, so the
       appeal was in the capacity of keeper, not as driver.
       Could anyone let me have an indication of whether the keeper's
       response to this latest correspondence from Parkingeye should be
       by the keeper or whether the keeper should now identify the
       driver.
       It does not seem clear to me whether the original NtK is
       sufficiently defective that Parkingeye cannot hold the keeper
       responsible in any event.
       I am trying to assist the keeper (who is unable to deal with
       this) and feel a bit like the blind leading the blind at the
       moment.
       #Post#: 63740--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: b789
       Date: March 22, 2025, 1:00 pm
       ---------------------------------------------------------
       So did you appeal as the Keeper and not identified the driver? I
       am not absolutely clear whether you are the Keeper and you are
       appealing as the Keeper because you were not the driver, or
       whether your friend is the Keeper and a different driver is the
       subject of this.
       I really hope you or your friend or whoever sent the appeal
       didn't just attach some random photos of the knee as "evidence"
       of the drivers disability. I already told you that a photo of
       the knee or a brace is not going to do the job!!!
       The response from ParkingEye is a standard template letter that
       appears to:
       [indent]• Ignore the content of the appeal, especially the
       detailed explanation regarding the driver’s disability;
       • Misstate PoFA by citing Schedule 4 paragraph 9(2)(b) while
       ignoring the requirement for full compliance under 9(2)(f)–(h)
       to establish Keeper liability;
       • Attempt to shift liability onto the Keeper without addressing
       the failure to form a contract or their duty to make reasonable
       adjustments under the Equality Act 2010;
       • Omit any reference to the Equality Act or the supplied medical
       evidence, which suggests the appeal was not meaningfully
       considered.[/indent]
       However, evidencing a protected characteristic under the
       Equality Act 2010 requires more than a photo of a scar or brace.
       For the mitigation to be properly considered under the Equality
       Act, the Keeper (on behalf of the driver) should ideally provide
       a written statement from a medical professional, such as:
       [indent]• A GP or consultant’s letter stating the nature and
       duration of the impairment;
       • Confirmation that the condition substantially affects the
       driver’s mobility;
       • A statement indicating that the condition is long-term and
       meets the statutory definition of a disability under section 6
       of the Equality Act 2010
  HTML https://www.legislation.gov.uk/ukpga/2010/15/section/6.[/indent]
       The strongest grounds lie in the Equality Act mitigation, and it
       is strategically cleaner for the Keeper to now name the driver
       and transfer liability, since:
       [indent]• The Equality Act defence only applies to the driver,
       and
       • POPLA (or any future court claim) would require evidence of
       the driver’s protected characteristic, which the Keeper cannot
       assert on their own account.[/indent]
       This is my suggested response to the letter from ParkingEye:
       --- Quote ---
       > Subject: Re: Parking Charge Notice [Insert Reference]
       >
       > Date of Issue: [Insert Date]
       > Vehicle Registration: [Insert VRM]
       >
       > Dear Sir/Madam,
       >
       > Dear Sir/Madam,
       >
       > Further to your recent correspondence, I now confirm the
       identity of the driver of the vehicle on the date of the alleged
       incident.
       >
       > The full name and current address for service of the driver
       is:
       >
       > [Full Name of Driver]
       > [Driver’s Postal Address]
       >
       > In accordance with Schedule 4, Paragraph 5(1)(b) of the
       Protection of Freedoms Act 2012, I am no longer liable for this
       Parking Charge Notice, and you are now required to pursue the
       driver directly.
       >
       > For the avoidance of doubt, this transfer of liability is made
       within the applicable time limits set out in Schedule 4, and the
       information provided is accurate. Please confirm that I will
       receive no further correspondence regarding this matter.
       >
       > Yours faithfully,
       >
       > [Full Name of Keeper]
       > Registered Keeper
       --- End Quote ---
       This shifts the matter to the driver, allowing the full Equality
       Act mitigation to be developed on their behalf in any subsequent
       appeal. The driver can then prepare a disability-based
       mitigation case supported by GP evidence, if necessary.
       #Post#: 63908--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: gliderpilot63
       Date: March 24, 2025, 4:06 am
       ---------------------------------------------------------
       Thanks b789. The keeper was the driver.  I am a friend and
       unrelated but able to at least try to gain knowledge from this
       website and to post documents for comment, which my friend is
       unable to do.
       Following your earlier advice, no photos were sent to evidence
       the medical issues, merely the narrative in the second draft
       letter.
       I shall tweak your draft response to reflect the fact that the
       keeper was in fact the driver.
       In that response, given that Parkingeye completely ignored the
       earlier reference to the driver's mobility impairment, should
       the driver's description of what occurred and the fact that his
       impairment was the cause of the extended consideration period be
       included again?
       #Post#: 63939--------------------------------------------------
       Re: Parkingeye Ltd - PCN - Overstay - Doncaster St. James
   DIR By: b789
       Date: March 24, 2025, 8:06 am
       ---------------------------------------------------------
       Unless you can get the driver to obtain a letter from their GP
       or Consultant that confirms their disability and that has lasted
       or is going to last for over 12 months, then they ParkingEye are
       not going to care and neither will they be obliged to unless the
       evidence it put before them.
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